The Austrian Association of Translators and Interpreters UNIVERSITAS, which has initiated and co-operated on Austrian national standards for translation and interpreting services (find attached the completed standards for translation services), is for several reasons opposed to the above-mentioned project. These reasons are given in the position of the Austrian Standards Institute (see the file kommentar_n1098 in the attachment mentioned above).

We believe that it would be in the interest of all free-lance translators and interpreters in Europe to counteract the adoption of a CEN Standard for Translation Companies which would override national standards, such as the Austrian ones.

To further our common cause, we should therefore ask you to request your National Standards Institutes to fashion the opinions they are going to submit to CEN on the position of the Austrian Standards Institute.

Thanking you in advance for your co-operation, I remain

Yours Sincerely,

Erika Obermayer, President\"

I read the attachments she points out in her letter and have to say she\'s absolutely correct.

Please read what the CEN Standard for Translation Companies would be all about (it\'s still a \'draft\') at

Austria appreciates the idea to elaborate European Standards for translation services and agrees with the principal objectives stated in document CEN N 1098.

Nevertheless Austria believes that the project as proposed by EUATC needs some amendments in order to be as widely as possible accepted among the translation service industry.

Genuine service standards vs. ISO 9001 approach

Austria believes that ISO 9001 is not an appropriate approach for the service industry in general. ISO 9001 refers to formal procedures to be applied, but does not (and is of course not able to) describe quality requirements for a specific product (or in this case a service) itself and of course not the qualification of the service provider. In particular the issue of the personal qualification of a translation service provider is crucial since translation is an intellectual service.

The market of translation service providers is characterised by very small companies and even more by free lance individuals. An ISO 9001 approach will put small service providers at risk of being pushed out of the market because such \"companies\" or individuals are not in the position to afford the costs of an ISO 9001 certification.

Austria thus proposes to follow a different approach. The Austrian standards

OENORM D 1200 \"Translation and interpretation services - Translation services - Requirements for the service and the provision of the service\", and

The above mentioned Austrian standards were drawn up by representatives of all relevant parties of the industry, e.g. the Austrian Professional Association of Translation companies with the Austrian Chamber of Commerce, the Austrian Association of Translators and Interpreters as well as representatives of the International Federation of Translators (FIT).

\"Translation service provider\" vs. \"Translation company\"

The EUATC proposal refers specifically to \"translation companies\", although a rather vague definition is given in the EUATC draft. Austria believes that is not the purpose of a (European) standard to imply per se that a particular part of the industry (i.e. free-lance translators) does not deliver a quality service by excluding this particular part of the industry from the scope of the standard. In fact such a standard for translation companies only, would be applicable only to a minor part of the translation industry. Austria therefore proposes to use the more generic term \"service provider\" for the scope of the project.

The Austrian proposals are as follows:

· to change the title of the project to \"Requirements for translation services\",

· to change the scope of the project from \"translation companies\" to \"translation service providers\",

As far as I\'m concerned, the above should be backed by all free-lance translators and interpreters worldwide, as an ISO 9001 approach will indeed put small service providers at risk of beeing pushed out of the market because such \"companies\" or individuals are not in the position to afford the costs of an ISO 9001 certification.

Simply put, we\'ll be in for a ride if the above proposed CEN Standard would indeed be implemented as such.

I wrote to Mrs. Obermayer about this issue and this is what she replied (dated December 1, 2001):

\"Dear Mr. Deloof-Sys,

Thank you for your mail.

We have just concluded work on the Austrian standards for interpreting.

On this occasion we also discussed the matter of the proposed CEN standard

for translation companies.

A first poll among national standards institutes which are members of CEN has shown that the majority has indicated approval.

(This may largely be due to a reluctance to give reasons for withholding approval).

It appears that a first CEN meeting on the matter is scheduled for January.

On behalf of the Austrian Association of Translators and Interpreters we

shall do our best to prevent the adoption of standards that leave the

concerns and interests of free-lance translators out of consideration, and

we shall fully support the position taken by the Austrian standards

institute which I attach.

If you see a chance of influencing your national standards institutes in

our common interests, I should be extremely thankful.

Yours truly,

Erika Obermayer\"

There you have it; now might be the time to really do something.

I would appreciate any and all comments possible on the topic, which I\'d then submit to Mrs. Obermayer, who could then take it from there in January.

What about it?

Avanti populo!

Kind regards and sincere thanks in advance for all comments,

Evert Deloof-Sys

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[ This Message was edited by: on 2001-12-07 08:37 ]

[ This Message was edited by: on 2001-12-07 08:43 ]

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